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- Title
Repairing the Crack in New Orleans' Black Vote: VRA's Results Test Nullifies "Gerryduck".
- Authors
Engstrom, Richard L.
- Abstract
In 1982, Section 2 of the U.S. Voting Rights Act was amended to allow plaintiffs to prevail in voting rights litigation if they demonstrate that a challenged law or practice has a discriminatory result. One of the first applications of this new statutory provision in validated a congressional districting plan for the New Orleans metropolitan area, a plan that had divided the city's black population virtually in half. This article reviews both the making and the unmaking of that plan, derisively known as the "gerryduck." Although the judicial action invalidating this exercise in racial cartography demonstrates the potential importance of this new section of the VRA as a legal weapon against minority vote dilution, the results test provides federal judges with enormous discretion, and the application of the test may therefore be quite capricious.
- Subjects
NEW Orleans (La.); LOUISIANA; SUFFRAGE; LAW; NULLIFICATION (States' rights); POLITICAL participation of minorities; METROPOLITAN areas; POLITICAL participation
- Publication
Publius: The Journal of Federalism, 1986, Vol 16, Issue 4, p109
- ISSN
0048-5950
- Publication type
Article
- DOI
10.1093/oxfordjournals.pubjof.a037612